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2 INTRODUCTION The purpose of this TAX INCENTIVE GUIDE is to explain the taxation regimes granted to those wishing to apply for tax incentives for producing and trading within the MANAUS FREE TRADE ZONE (ZFM-ZONA FRANCA DE MANAUS), THE WESTERN AMAZON AND THE FREE TRADE AREAS (FTAS). It is therefore our intention to summarize the benefit package administered by SUFRAMA in an informative and practical manner. Please note that, as is always the case with tax procedures in Brazil, the content of this publication should be treated as a guide only and the relevant statutory source should be referred to in all matters pertaining to it, especially the actual content and effective stipulations of provisional measures, laws, decrees and other rules implemented in response to regional and national socioeconomic issues affecting SUFRAMA tax initiatives. THOMAZ AFONSO QUEIROZ NOGUEIRA Superintendent - SUFRAMA 2

6 INTRODUCTION The incentives addressed in this guide relate to tax exempt areas within Western Amazon and the municipalities of Macapá and Santana, in the State of Macapá. Tax incentives for the Manaus Free Trade Zone (ZFM Zona Franca de Manaus), Western Amazon (AMOC Amazônia Ocidental), and Free Trade Areas (FTAs) are administered by the Superintendence of the Manaus Free Trade Zone SUFRAMA. SUFRAMA is a federal body linked to the Ministry for Development, Industry and Foreign Trade (MDIC), as established by Article 10 of Decree-Law no. 288, dated February 28, 1967: Article 10. The administration of facilities and services of the Free Trade Zone shall be the responsibility of the Superintendence of the Manaus Free Trade Zone SUFRAMA, a federal body having own corporate identity and equity, financial and administrative independence, with head offices and jurisdiction in the city of Manaus, the capital of the state of Amazonas. SUFRAMA s mission is to: Promote regional economic development by generating, attracting and consolidating investments based on education, science, technology and innovation, in order to achieve nationwide integration and competitiveness in the international market. (Strategic Plan) 6

7 1 UNDERSTANDING THE TAX POLICIES OF THE ZFM, FTAs AND WESTERN AMAZON The Manaus Free Trade Zone is a free trade area for import and export operations. It enjoys certain special tax incentives established for the purpose of promoting regional development by creating an industrial, farming and cattle raising and commercial hub where economic conditions permit growth regardless of regional factors and the far distances from the markets where its goods are consumed, as set forth in Article 1 of Decree-Law no. 288, dated February 28, 1967, Article 1 of Decree-Law no. 356, dated August 15, 1968, and Article 504 of Decree-Law no. 6,759, dated February 05, As a result, the region s development has been focused on three sectors of the economy, namely the primary, secondary and tertiary sectors. From a more focused perspective, the area s special tax status establishes four scenarios that imply the granting of tax benefits, namely: 1 st SCENARIO: IMPORTING GOODS INTO THE ZFM, WESTERN AMAZON, AND FTAs. 2 nd SCENARIO: DOMESTIC (NATIONALIZED) GOODS BEING PURCHASED BY THE ZFM, WESTERN AMAZON, AND FTAs. 3 rd SCENARIO: GOODS BEING EXPORTED BY THE ZFM, WESTERN AMAZON, AND FTAs. 4 th SCENARIO: SALES OF PRODUCTS FROM THE MANAUS FREE TRADE ZONE, THE WESTERN AMAZON REGION, AND FREE TRADE AREAS. 7

8 1.1 - SCHEMATIC OVERVIEW OF THE TAX INCENTIVE SYSTEM MAP OF WESTERN AMAZON 8

10 2 OVERVIEW OF INCENTIVES 1 st SCENARIO: IMPORTING GOODS INTO THE ZFM, WESTERN AMAZON, AND THE FTAs 1 IMPORT DUTY 1.1 MANAUS FREE TRADE ZONE AND WESTERN AMAZON a) Exemption from Import Duty on foreign goods entering the ZFM intended for internal consumption, manufacture to any degree, including processing, such as farming or cattle raising products, fish products, facilities and operation of industries and services of any type, and storage for re-export, With the exception of weapons and ammunition, tobacco, alcoholic beverages, passenger vehicles; perfumes or vanity goods, prepared cosmetics and cosmetic preparations, excluding those classified in positions 3303 and 3307 of the Brazilian Customs Tariff TAB 1 are exclusively intended for internal consumption within the Manaus Free Trade Zone or produced using raw materials originating from the region s flora and fauna, in compliance with basic production processes. Decree-Law no. 288/67, Article 3, Paragraph1; Decree-Law no. 356/68, Article 1; Law no. 8,032/90, Article 4, Law no. 8,387/91, Article 1; b) Reduction of Import Duty on exiting goods manufactured in the Manaus Free Trade Zone destined to any location within the Brazilian territory. b.1) Information Technology Goods reduction rate resulting from the ratio of the value of domestic raw materials and other inputs, the cost of labor used in the production process, and the costs of raw materials and other domestic and Perfumes and Toilet Waters; Beauty or make-up products and skin care preparations (other than medicaments), including sunscreen or sun tan preparations; manicure or pedicure preparations; Preparations for use on the hair; Preparations for oral or dental hygiene, including denture fixative pastes and powders; yarn used to clean between the teeth (dental floss), in individual retail packages, and Preshave, shaving or after-shave preparations, personal deodorants, bath preparations, depilators and other perfume or vanity goods and prepared cosmetics, and cosmetic preparations, not elsewhere specified or included, prepared room deodorizers, whether or not perfumed or having disinfectant properties. 10

12 2.2 FREE TRADE AREAS FTAs Exemption from excise tax on entry of foreign goods intended for internal sale and consumption, manufacture of products in its territories 3, cattle processing 4, fish processing, mineral resources and agricultural or forest raw materials, agricultura 5, farming and cattle raising and pisciculture, tourism and storage for export 6, for ship manufacture and repairs 7 and landed costs related to accompanied luggage, except for weapons and ammunition, tobacco, alcoholic beverages, passenger vehicles, perfume and finished goods for IT 8. Decree no. 7,212/2010, Article 106, New IPI Regulation; Law no. 7,965/89, Tabatinga FTA, Articles 3 and 13; Law no. 8,210/91, Guajará Mirim FTA, Articles 4 and 13; Law no. 8,256/91, Boa Vista and Bonfim FTA, Articles 4 and 14; Law no. 8,387/91, Macapá and Santana FTA, Article 11, Paragraph 2; Law no. 8,857/94, Brasiléia and Cruzeiro FTA, Article 4; Decree no. 6,759/2009 Customs Regulations, Articles 525 and IMPORT-RELATED PIS/PASEP and COFINS 3.1 MANAUS FREE TRADE ZONE The calculation of the customs value 9 of foreign goods entering Brazil will be in accordance with the new wording in Law 12,865, Article 26 of 2013 for the purpose of calculating the PIS/PASEP and COFINS, which are both linked to imports. a) In general, PIS/PASEP rate is 1.65%, having the following variations for the goods listed below: I - Pharmaceuticals 2.10% 3 Manufacture of products restricted to the Tabatinga, Brasileia and Cruzeiro do Sul FTAs 4 Restricted activity to the Boa Vista, Bonfim, Macapá, Santana, Brasileia and Cruzeiro do Sul FTAs 5 Restricted activity to the Guajará-Mirim FTA 6 Restricted activity to the Tabatinga FTA 7 Ship manufacture and repair activities limited to the Guajará-Mirim and Tabatinga FTAs 8 The list of exceptions for finished information technology goods applies to the Tabatinga and Guajará-Mirim FTAs 9 Article 4 - When assessing the customs value, regardless of the customs valuation method, the following elements shall be included: I - the cost for transporting imported goods to the unloading customs port or airport or the customs border points where customs territory entry formalities must be met; II - costs related to loading, unloading and handling associated to the transport of imported goods until arrival to the locations referred to in the previous item; and III - costs related to the insurance of the goods during the operations referred to in items I and II. Source: SRF Normative Ruling No. 327, dated May 9,

13 II - Perfumes 2.20% III - Machinery/vehicles 2.00% IV - Auto parts 2.30% V - Paper (exempt) 0.80% Article 7, item 1, of Law no. 10,865, dated April 30, 2004; Article 8, Paragraphs 1 to 10, Law no. 10,865/2004. Article 26, of Law 12,865, dated October 9, Brazilian Federal Revenue Department Normative Ruling No. 1,401/13. b) Import-related COFINS a rate of 7.60% is typically applied upon entry, with the following variations for the goods listed below: I - Pharmaceuticals 9.90% II - Perfumes 10.30% III Machinery/vehicles 9.60% IV Auto parts 10.80% V - Paper (exempt) 3.20% Article 8, paragraphs 1 to 10, Law no. 10,865/2004. Article 7, item 1 of Law no. 10,865, dated April 30, Brazilian Federal Revenue Department Normative Ruling No. 1,401/13. c) Suspension of import-related PIS/PASEP and COFINS Duty payable on new goods destined for incorporation in the property, plant and equipment of a company located within the Manaus Free Trade Zone. Suspension will be converted into a zero tax rate after a period of eighteen months has elapsed from the date when the good has been incorporated into the importing company s fixed assets. Law no. 10,865/2004, Article 14, Paragraph 1; Law no. 11,196/2005, Article 50; Decree no. 5,691/2006, Article 1. d) Suspension of PIS/PASEP and COFINS on imports by companies located within the Manaus Free Trade Zone of raw material, intermediate products and packaging materials, for use in manufacture processes by industrial plants located within the ZFM with projects approved by Suframa. 13

14 Law no. 10,865/2004, Article 14-A; Law no. 10,925/2004, Article 5 2 nd SCENARIO: DOMESTIC OR NATIONALIZED (*) GOODS BEING PURCHASED BY THE ZFM, WESTERN AMAZON AND FTAs 1 EXCISE TAX Internal Operations MANAUS FREE TRADE ZONE AND WESTERN AMAZON a) Exemption from excise tax for all goods produced in the ZFM intended for internal consumption or commercialization anywhere within the Brazilian territory, except for weapons and ammunition, tobacco, alcoholic beverages, and passenger vehicles. Decree-Law no. 288/67, Article 9, Paragraph 1; Law no. 8,387/91, Article 1. Constitutional Amendment no. 42. Law no. 9,065/95, Article 19. b) Equivalence to a Brazilian export abroad when goods originating in Brazil are shipped for consumption or manufacture within the ZFM, or re-exported abroad, or shipped to Western Amazon. Decree-Law no. 288/67, Article 4; Decree-Law no. 356/68, Article 1. c) Tax Exemption for products made out of raw materials of agricultural and vegetal gathering origin produced regionally, except of cattle raising origin, by any company located at Western Amazon. Decree-Law no. 1,435/75, Article 6. (*) Pursuant to CONSULTATION SOLUTION/SRF no. 448, dated November 16, 2006, the IPI (excise tax) exemption applicable to the ZFM, as specified in Article 69, item III of RIPI/02, along with the suspension of IPI taxation, as referred to in Article 71 14

15 of the same rule, relates in general to domestic goods, which are those derived from any of the manufacture operations mentioned in Article 4 - RIPI/02 performed in Brazil. However, the benefit is extended to foreign goods that are nationalized and resold to customers located in said region, if such goods are imported from nations that guarantee equal treatment to the goods imported from those nations and equivalent domestic goods, based on any international agreement, treaty or convention of which Brazil is a signatory. This is the case, e.g., of imports originating from Mercosur member states (pursuant to Article 7 of the Mercosur Treaty and ratified by Decree no. 350/1991) and the nations who are signatories to the GATT agreement, or which may have adhered to it (pursuant to the provisions of Paragraph 2, Article III, Part II of this Treaty and ratified by Law no. 313/1948). Article 98 - Law no. 5,172/1966 CTN Article 69, item III and Article 71 of Decree no. 4,544/2002 RIPI/02 Pursuant to CONSULTATION SOLUTION No. 11, DATED JANUARY 22, 2007, the IPI exemption referred to in Article 69, item III and Article 82, item 1 of RIPI/2002 is limited to domestic goods, which are defined as being those derived from any of the manufacture operations mentioned in Article 4 therein being performed in Brazil. However, the benefit also applies to nationalized foreign goods when they originate from nations that guarantee equal treatment for both the domestic good and the one imported from a nation party to any international agreement, treaty or convention of which Brazil is a signatory. EXEMPTION: FREE TRADE AREAS (FTAs) NATIONALIZED GOODS. The IPI exemption on goods entering the Free Trade Areas (FTAs), as set forth in Articles 93, 96, 99, 102, and 105 of RIPI/2002, applies to domestic and nationalized goods, regardless of the country these nationalized goods have been imported. Nevertheless, in order to qualify for this exemption, said goods must be sent to companies authorized to operate within the respective Free Trade Area and must be destined for use in the manner as set forth in Articles 92, 96, 98, 101, and 104 of RIPI/2002 for each specific FTA. 15

17 2 PIS/PASEP and COFINS 2.1 MANAUS FREE TRADE ZONE, WESTERN AMAZON AND FREE TRADE AREAS a) In general, the PIS/PASEP rate is 1.65% on the total amount of the purchase invoice from other States, applicable both to industry and commerce, and the respective reduction to zero. Article 17 of Law no. 11,033, dated December 21, 2004; Article 2, Paragraph 3 of Law no. 10,996 dated December 15, Article 65, paragraph 8 of Law no. 11,196/2005. COFINS related to Domestic Purchases generally, the incentive is applied a rate of 7.6% on the total amount of the purchase invoice from other States, applicable for both industry and commerce, and the respective reduction to zero. Article 17 of Law no. 11,033, dated December 21, 2004; Article 2 of Law no. 10,996/2004 and Article 65, Paragraph 8 of Law no. 11,196/2005 SUMMARY TABLE PURCHASE OF DOMESTIC GOODS PURCHASE OF DOMESTIC GOODS BY: PIS/PASEP COFINS ZFM, WESTERN AMAZONIA, AND FTAs 1.65% 7.60% DOMESTIC PURCHASE INCENTIVES (Using SUFRAMA / Sinal Systems) Reduced to Zero Reduced to Zero b) Reducing PIS/PASEP and COFINS to zero as applicable to revenue from sales of goods intended for consumption or manufacture in the Manaus Free Trade Zone and Free Trade Areas by legal entities located outside the ZFM. Law no. 10,996/2004, Article 2; Law no. 11,196, dated November 21, 2005, Article 65, Paragraph 8 Decree no. 5,310/04; Law no. 11,945/2009, Article 24. c) Reducing PIS/PASEP and COFINS rate contributions to zero as applicable to revenue from the commercialization of raw materials, intermediate products and 17

18 packaging materials produced in the Manaus Free Trade Zone for use in manufacture processes by industrial plants located at the ZFM itself and in accordance with projects approved by the Administrative Council of the Superintendence of the Manaus Free Trade Zone (CAS). Law no. 10,637/2002, Article 5 A; Law no. 10,865/2004, Article 37; Decree no. 5,310/ rd SCENARIO: GOODS EXPORTED BY THE ZFM, WESTERN AMAZON, AND THE FTAs The Manaus Free Trade Zone is a free trade area that also grants export incentive as laid down in Article 1 of Decree-Law No. 288/1967: Article 1: The Manaus Free Trade Zone is a free trade area for imports and exports with special tax incentives, which has been established with the aim of creating an industrial, commercial and farming and cattle raising hub in Amazon's inland provided with economic conditions that allow it to develop, regardless of local factors and the long distance from the centers that consume its products. 1- EXPORT DUTY: ZFM AND WESTERN AMAZON AND FREE TRADE AREAS (ALCs) Exemption (Article 5, paragraph 3, of Decree-Law no. 288/1967): 2- PIS/PASEP: Article 5. The export of goods, regardless of their origin, from the Manaus Free Trade Area to other countries is exempt from export tax ZFM AND WESTERN AMAZON AND FREE TRADE AREA Non-applicability (Law No. 10,637/2002 Article 5, items I and III): Article 5. The PIS/Pasep contribution shall not 18

19 apply to income originated from the following transactions: I - export of goods to other countries; (...) III - sales to export trade businesses for export purposes 3 - COFINS: ZFM AND WESTERN AMAZON AND FREE TRADE AREA Non-applicability (Law No. 10,833/2003, Article 6, items I and III): Article 6. COFINS shall not apply to income from the following transactions: I - export of goods to other countries; (...) III - sales to export trade businesses for export purposes. 4 th SCENARIO: SALES OF PRODUCTS FROM THE MANAUS FREE TRADE ZONE, THE WESTERN AMAZON REGION, AND FREE TRADE AREAS. The Manaus Free Trade Zone grants tax incentives on Sales Operations to commerce and industry in the following situations: 1 EXCISE TAX Internal Operations 1.1 THE MANAUS FREE TRADE ZONE AND THE WESTERN AMAZON REGION Tax exemptions on ZFM goods, intended for internal use or for any degree of manufacture, including processing, farming and cattle raising, fish products, facilities and operation of industries and services of any type, and storage for re-export. 10 (Decree-Law No. 288/1967 Article 3): Article 3 The entry of foreign goods into the Free Trade Zone, intended for internal consumption, any degree of manufacture, including processing, farming or cattle raising products, fish products, facilities and operation of industries and services of any type, and storage for re-export, shall be exempt from import duty and excise tax. 10 With the exception of weapons and ammunition, tobacco, alcoholic beverages, passenger vehicles; perfumes or vanity goods, prepared cosmetics, and cosmetic preparations, excluding those classified in positions 3303 and 3307 of the Mercosur Common Nomenclature, if intended exclusively for internal consumption in the Manaus Free Trade Zone or when produced using raw materials originating from the region s flora and fauna, in compliance with basic production processes. 19

20 Products manufactured in the ZFM and commercialized internally or sent to another state (Decree-Law No. 288/1967, Article 9 and Decree No. 7,212/2010, Article 81, Items I and II): DECREE-LAW No. 288/1967 ARTICLE 9 Article 9: All goods produced in the Manaus Free Trade Zone are exempt from Excise Tax (IPI), whether they are intended for internal consumption or for commercialization anywhere in Brazil. (Text given in Law 8,387 dated December 30, 1991) Paragraph 1: The exemption dealt with in this article, concerning products manufactured in the Manaus Free Trade Zone which must be used in other regions of Brazil shall be conditional on compliance with the requirements laid down in Article 7 of this Decree-Law. (Included by Law 8,387 dated December 30, 1991) Paragraph 2: The exemption dealt with in this Article does not apply to the goods referred to in Article 3, Paragraph 1 of this Decree-Law. (Included by Law 8,387 dated December 30, 1991) DECREE No /2010, ART. 81, ITEMS I AND II Article 81: The following are exempt from tax (Decree- Law No. 288, Article 9 dated February 28, 1967, and Law 8,387, Article 1, dated 1991): I products manufactured in the in the Manaus Free Trade Zone, intended for internal consumption, excluding weapons and ammunition, tobacco, alcoholic beverages and passenger vehicles II - products manufactured in the in the Manaus Free Trade Zone, by businesses with projects approved by the Board of Directors of the Superintendence of the Manaus Free Trade Zone (SUFRAMA), which are not manufactured by conditioning or reconditioning, intended for commercialization anywhere else in Brazil, excluding weapons and ammunition, tobacco, alcoholic beverages, passenger vehicles; perfume and vanity goods, prepared cosmetics and cosmetic preparations, unless these (Positions to of the IPI Table) are produced using raw materials originating from the region s flora and fauna, in accordance with Basic Productive Processes. 20

21 Products prepared from raw materials of agricultural or vegetable gathering origin, except for raw materials of cattle raising origin, by businesses located in the Western Amazon Region. (Decree-Law No. 1,435/75, Article 6) Article 6: Products prepared from raw materials of agricultural or vegetable gathering origin, except for raw materials of cattle raising origin, by businesses located the area defined in Decree-Law No. 291, Article 1, Paragraph 4, dated February 28, 1967, are exempt from Excise Tax. Paragraph 1: The products referred to in the heading to this article shall generate Excise Tax credits, calculated as if due, whenever used as raw materials, intermediates or packagings materials, in the manufacture of products, anywhere in Brazil, when these are actually subject to payment of the above tax. Paragraph 2: The tax incentives described in this article apply exclusively to products prepared by industrial entities whose projects have been approved by SUFRAMA. 1.2 FREE TRADE AREAS Products manufactured in the FTAs, composed predominantly of raw materials of regional origin extracted from the animal, vegetable and mineral segments 11, are exempt 12 from IPI, as laid down in Law No. 11,898, dated January 8, 2009, as shown below: Article 26: Products manufactured in the free trade import and export area covered by Laws No. 7,965, of December 22, 1989, No. 8,210, of July 19, 1991, No , of December 30, 1991, and No. 8,857, of March 8, 1994, are exempt from Excise Tax, whether they are intended for internal consumption, or for commercialization anywhere else in Brazil. Paragraph 1: The exemption described in the heading to this article only applies to products composed predominantly of raw materials of regional origin extracted from the animal, vegetable and mineral 11 With the exception of the mineral ores in Chapter 26 of the Mercosur Common Nomenclature (MCN), or the agrosilvopastoral system 12 The exemption laid down in Article 26 of the law applies exclusively to products prepared by industrial entities whose projects have been approved by the Superintendence of the Manaus Free Trade Zone 21

22 segments, with the exception of the mineral ores in Chapter 26 of the Mercosur Common Nomenclature (MCN), or the agrosilvopastoral system, in compliance with the relevant environmental legislation and as defined in regulations. Paragraph 2: The exemption in the heading to this Article does not apply to weapons and ammunition, tobacco, alcoholic beverages, passenger vehicles, perfume or vanity goods, prepared cosmetics and cosmetic preparations, except those classified in positions 3303 to 3307 of the CNM, where intended exclusively for internal consumption in the free trade areas referred to in the heading of the article above or when produced using raw materials originating from the region s flora and fauna, in accordance with basic productive processes and the preponderance mandated in Article 26, Paragraph 1, of this Article. 2 PIS/PASEP and COFINS 2.1 MANAUS FREE TADE ZONE AND FREE TRADE AREAS PIS: Reduction in tax rate ZFM and FTAs: (Law No. 10,637, Article 2, Paragraphs 4 and 5 of December 30, 2002, and Law No. 10,996/2004 Article 2, Paragraphs 4, 5 and 6). The incentive consists of a reduction in tax rates applied to sales operations for goods produced in the Manaus Free Trade Zone and sold by an industrial company established in the ZFM, with a SUFRAMA approved project, through the application of a differentiated tax rates 13. This incentive also applies to the gross revenue of legally constituted industrial or commercial entities established in the Free Trade Areas. LAW No. 10,637/2002, ARTICLE 2, PARAGRAPHS 4 AND 5 Article 2: To determine the PIS/PASEP to be levied, a rate of 1.65% (one point six five percent) will be applied, to the calculated tax base, as laid down in Article See Table I 22

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